By Xiufang (Ava) Tu and Lina Zhou, with Federico Patuelli (EU team)
EU sanctions have increasing implications for Chinese banks, energy companies and traders.
Since February 2022, the EU has progressively expanded its sanctions framework against the Russian invasion of Ukraine.[1] In the 18th and 19th sanctions packages, adopted in the second half of 2025, Chinese financial institutions and companies considered by the EU to be directly or indirectly supporting Russia’s war in Ukraine were also listed.
Building on this trend, the forthcoming 20th sanctions package, initially set for February 23, 2026, is expected to further reinforce the Council’s focus on third‑country actors, notably financial, energy, trading and logistical operators involved in Russian supply chains, with increased attention to energy‑related infrastructure and external choke points located outside the EU.
18th sanctions package
On July 18, 2025, the Council adopted its 18th sanctions package. For the first time, this sanction list included two Chinese financial institutions: Heihe Rural Commercial Bank Co. Ltd. and Suifenhe Rural Commercial Bank Co. Ltd. These banks were targeted due to their involvement in crypto-related services.
The measures include secondary restrictions, applying to entities located outside of the EU, which could potentially aid the circumvention of the Russia against EU sanctions, in particular through financial supports. Accordingly, the aforementioned two Chinese banks have been added onto the list.[2]
In addition, this 18th package imposed stricter export controls concerning dual-use goods and advanced technologies. A total of twenty-six new entities will be subject to these tighter export restrictions, we noticed that seven entities are located in China and Hong Kong. [3]
19th sanctions package
On October 23, 2025, the Council adopted the 19th sanctions package which included twelve Chinese companies.
In the energy sector, a total ban on import of Russian Liquefied Natural Gas (LNG) has been imposed:
- for long-term contracts as of January 1st, 2027, and
- for short-term contracts within 6 months of the entry into force of the measures.
The EU also introduced measures against important third-country operators that enable Russia’s revenue streams. In this respect, two Chinese refineries – Liaoyang Petrochemical Company and Shandong Yulong Petrochemical Co., Ltd. – as well as the oil trader Chinaoil Hong Kong Corporation Limited have been added to the sanctions list.[4]
Through these measures, the EU sought to further drain Russia’s funds by reducing vital oil and gas revenues, taking the view that these three Chinese companies have been significant buyers of Russian crude oil.
The 19th package further expanded export restrictions and bans. These measures affect third-country operators from China producing and supplying military and dual-use goods to Russia. Forty-five new entities have been added to the sanction list: twelve are based in China or Hong Kong.[5]
Challenging the application of restrictive measures
Listed persons and entities residing outside of the EU can request the Council to reconsider its decision through a motivated request to the Council. In parallel, judicial review of the listing decision must be sought before the General Court of the European Union.
The proceedings must be instituted within two months and fourteen days of the publication of the measure, or within two months of notification of the listing decision, as applicable.[6]
What’s next? 20th package
On February 6, the EU has proposed its 20th sanctions package. The EU intends to further expand and tighten its existing sanctions to further pressure Russia in order to end the war in Ukraine.
The adoption of the 20th sanctions package, initially expected on February 23, 2026, is currently on hold due to the opposition of certain Member States; however, its adoption is expected in the near term.
This package is expected to continue the approach taken in previous rounds, focusing on entities perceived as enabling sanctioned Russian businesses or facilitating circumvention. Areas of attention may include the shadow fleet, circumvention networks and financial support structures, as well as operators involved in purchasing or enabling the purchase of Russian energy, financial institutions facilitating financing for Russian entities or related transactions, and traders and logistics providers supporting these flows.
The new sanctions package shall cover energy, financial services and trade,[7] with particular attention to maritime and energy‑related choke points. In this context, EU institutions have increasingly signalled their readiness to extend enforcement to critical infrastructure located in third States, including ports and port operators handling Russian oil and petroleum products.[8] This may include ports involved in transhipment, blending, ship‑to‑ship transfers or logistical services connected to Russian crude exports, even where those ports are located outside the EU.
Such an approach would mark a further step in the EU’s use of secondary‑effect sanctions, potentially exposing port authorities, terminal operators, shipping service providers and energy logistics companies in China and other third countries to restrictive measures where their activities are considered to materially support Russian energy revenues.
Chinese businesses in sectors such as energy, finance, trading, shipping, ports and logistics should anticipate possible new restrictions and review exposures to Russia-related EU transactions.
The 20th sanctions package is expected to be adopted by the Council in the coming weeks.
We will continue monitoring the adoption of the 20th package and provide you with updates in relation to implications for Chinese entities.
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[1] Council of the EU, “Timeline – Packages of sanctions against Russia since February 2022,” Consilium (consulted on 31 December 2025): Timeline – Packages of sanctions against Russia since February 2022 – Consilium.
[2] Council of the EU, “Russia’s war of aggression against Ukraine: EU adopts 18th package of economic and individual measures”, 18 July 2025, Consilium: Russia’s war of aggression against Ukraine: EU adopts 18th package of economic and individual measures – Consilium.
[3] Ibid.
[4] European Commission, “EU adopts new sanctions against Russia,” 23 October 2025, European Commission: EU adopts new sanctions against Russia – European Commission; European Commission, “EU sanctions tracker” (consulted on 31 December 2025): Entities | EU sanctions tracker.
[5] Ibid.
[6] Articles 263 of the Treaty on the Functioning of the European Union.
[7] European Commission, “Statement by President von der Leyen on the 20th package of sanctions
against Russia”, 6 February 2026, European Commission: EU adopts new sanctions against Russia – European Commission.
[8] EU proposes sanctions on Georgian, Indonesian ports for handling Russian oil | Reuters.